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with the offender concerning their sick call complaint, and discuss what should be done. If a pelvic exam is necessary. The CNA will "set-up" for this procedure. The offender is then asked to remove her clothing from ...
Brief • 2005
) (citation omitted); see Connecticut Nat’l Bank, 503 U.S. at 253-54 (“[C]ourts must presume that a legislature says in a statute what it means and means in a statute what it says there.”); see also Conroy v ...
Brief • 2004
circuitously acquires a license to do precisely what Layne prohibited. For second and later reviews postLayne, the matrix grid has been disemboweled because guideline boundaries no longer function as benchmarks ...
Brief • 2011
to represent themselves in detention or removal 2 proceedings.” What they do contend is that Plaintiffs have already been diagnosed as 3 mentally incompetent and therefore do not need competency evaluations ...
,’ Humanism’s focus is less on what any one individual can do for himself and more on the cooperative effort of many individuals to effect the betterment of society. Affiliates and chapters of the American ...
that inmate Harvey abandoned his grievance because he was promised exactly what he sought. But Coats cannot argue that he withdrew his grievance in reliance on the promise of immediate Interferon treatment ...
Brief • 2006
2006 Metzner Report Appendix I at 18 (Inmate 11),20 (Inmate 12),22 (Inmate 13).2 At intake, the ACF counselor indicated that she was "at a loss of what to do" regarding the treatment of these prisoners ...
level of care. However, what was surprising was the lack of intensive treatment provided: treatment plans are not adjusted or revised to address on-going or worsening symptoms; medication adjustments ...
Brief • February 7, 2012
with Disabilities Act (“ADA”). See id. at 605. As the Court explained, a defendant's “voluntary change in conduct, although perhaps accomplishing what [a plaintiff] sought to achieve by the lawsuit, lacks ...
LOSORELLI contacted LASD Detective Welch – the LASD official who 4 arrested Mr. Losorelli on July 24, 2013. Plaintiffs asked Detective Welch for 5 advice on what to do during this interim period while ...
pornography on his tablet and instructing them not to bathe until he tells them to. He frequently taunted and threatened Ms. Morales and Ms. Herrera by telling them what time of night he will be coming ...
and HERNANDEZ are currently incarcerated in what ACSO names “administrative segregation” which is essentially solitary confinement. Plaintiff UPSHAW has been 24 previously housed in a 2-person cell. Plaintiff ...
to location-monitoring services. Libre encourages its representatives to mislead clients and co-signers about what its written agreement requires. 93. Libre’s incentive-compensation program rewards ...
Brief • February 26, 2020
Filed under: Failure to Treat
Complaint and Jury Demand as follows: INTRODUCTION 1. On July 31, 2018, at 10:44 a.m., Plaintiff Diana Sanchez gave birth to a baby boy, J.S.M. But what should have been one of the happiest days of her life ...
Brief • June 12, 2023
or based upon general nursing standards, is relevant to the elements of a deliberate indifference claim.”). That is exactly what Mr. Suarez has alleged. 2 11 Case 7:20-cv-07133-VB Document 156 Filed 06/12 ...
Brief • May 26, 2023
needs to be familiar with what you plan to present since he/she may be attending as 12 well.” (Id. ¶ 16.) (Id. ¶ 13.) The CIRB 13 David Myers, a former San Diego County Sheriff’s Department Captain ...
Brief • October 26, 2023
Filed under: Failure to Treat
protein,” or words to that effect, is what the member of the Plaintiff Class heard. He was so infuriated by the incident that he wrapped up samples of his food and sent it to a court for a request ...
Brief • December 16, 2023
Filed under: GPS Tracking Device
requirements mean that people are restricted in what they can do when. Shopping, entertainment, attending religious services, or spending time with family and friends must be either avoided or scheduled around ...
Brief • April 11, 2018
Filed under: Wrongful Death
recovery, Ms. Quintana concluded that “what would save him was the system,” because he would be properly monitored in jail. ADF’s Years-Long, Well-Documented Knowledge of Mr. Ortiz’ History of Opiate Abuse ...
Brief • November 1, 2018
Filed under: Censorship
substantial additional costs for in-person visits, which necessarily limits what these attorneys can do for these and other clients. DOC facilities prohibit attorneys from hand-delivering documents ...
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